WCM has an obligation to provide accurate and ethical stewardship of grant funds and the Office of Research Compliance (ORC) is dedicated to serving the WCM research community by ensuring that this takes place.
The ORC, with significant input from faculty and administrators, has developed a system called the Effort Tracking System (ETS). The ETS is a centralized repository of information on personnel's Committed Effort, Actual Effort and Other Activities. WCM subscribes to a plan confirmation system for certifying effort with the federal government.
The ETS should be used to record fluctuations in effort throughout a fiscal year so the year end certification and quarterly informational reports using SAP can be more accurately reported. It therefore makes keeping track of and reporting effort more efficient for PI's and administrators, and its use is required by WCM for all departments.
Monitoring and Audits
Quarterly the ORC will run a 100% effort report from the Effort Tracking System for each department. The time period will follow two quarters behind to allow adjustments in the system. The purpose of this audit is to identify areas that departments are having difficulty maintaining compliance as it relates to personnel’s effort. Where problems with compliance have been identified there will be additional education and training offered to the parties concerned.
Areas the audit will focus on are:
- Personnel over committed
Committed effort may not exceed the caps listed below (percentage of Total Effort);
- Chair/Division Chief must limit their funded research effort to 90%
- All other personnel must limit their funded research effort to 98%
- Projects not entered in ETS compared to the Coeus database
- The Coeus database keeps a record of all of the Federal Awards and Non-Federal Awards submitted to funding agencies through the Office of Sponsored Research Administration (OSRA).
- Projects not entered in ETS compared to the Activity Distribution Report
- The Activity Distribution Report (ADR) is a certified form used by WCM to document the proportion of Total Effort devoted by an employee to each activity with which he or she is involved, including sponsored projects, administration and teaching.
- Effort not updated – actual or committed and Total effort (Funded and Other) is accounted for -100%
- The 100% effort in ETS is a combination of the Funded Projects and Other Activities effort, which combined must total 100%.
- Research Compliance Training module completed
- The Research Compliance Training (RCT) that must be completed by all investigators, faculty, academics, key personnel and administrators involved in research.